Limits on business interest expense deductions

By Brian E. Ravencraft, CPA, CGMA, Partner at Holbrook & Manter, CPAs

One provision of the 2017 Tax Cuts and Jobs Act (TCJA) that has generated considerable concern among business owners is the new limitation on deductions for business interest expenses.

Prior to the provision, interest paid on business loans or credit lines could be deducted as an ordinary business expense. One section of the Internal Revenue Code — Section 163(j) —limited the deductions for certain types of interest expense that some C corporations paid, but most businesses were able to fully deduct business interest expense in the year it was accrued or paid.

The TCJA significantly changed that. The act expanded Section 163(j) to apply to all types of business interest expense, and it broadened the section’s scope to encompass all businesses, including pass-through entities such as partnerships, S corporations, and sole proprietorships.

Fortunately, many businesses — particularly small businesses — are still exempt from the Section 163(j) limitation. For tax year 2019, businesses (other than tax shelters) are exempt if their average annual gross receipts for the preceding three years were $26 million or less. This threshold amount is adjusted for inflation annually, so businesses with fluctuating revenues around that level could find they qualify for the exemption in some years but not in others. For purposes of this test the gross receipts of commonly owned entities must be aggregated.

Certain real property and farming businesses are permitted to opt out of the new business interest expense limitation, but only if they agree to use the Alternative Depreciation System (ADS) to depreciate certain long-term assets. The ADS usually result in lower depreciation deductions than the standard rules, so opting out of the business interest limitations might not be advisable. Moreover, this election is irrevocable.

Some regulated utilities and pipeline businesses whose rates are established by specified governing bodies are also exempt from the new limits.

New limits and special rules

For businesses that do not qualify for these exemptions, business interest expense deductions are now limited to the sum of three parts:

  1. Business interest income
  2. Thirty percent of adjusted taxable income (ATI)
  3. Interest expense for floor plan financing used by big-ticket retailers such as auto, boat, and appliance dealers

Note that the definition of ATI will be changing. For now, ATI is equal to earnings before interest, taxes, depreciation, and amortization (EBITDA), but for tax years beginning after Dec. 31, 2021, ATI will include deductions for depreciation and amortization, making it equivalent to EBIT.

Any interest expense that is disallowed under the new rules can be carried forward indefinitely, so it eventually could be treated as business interest expense in a future tax year. It is a relatively straightforward process for regular C corporations, but it gets more complicated with pass-through entities.

In a partnership, any interest expense in excess of the limit is passed through to the partners and carried forward on their individual returns. In S corporations, on the other hand, unused deductions are not passed through to shareholders; they are carried forward at the entity level until they can be used.

IRS Form 8990, “Limitation on Business Interest Expense Under Section 163(j),” provides some basic guidance, but businesses with revenues approaching or above the $26 million threshold should consult their accountant to develop strategies to deal with the new limits.

Please consult your CPA about this matter. As always, feel free to reach out to me with questions.


Brian E. Ravencraft, CPA, CGMA is a Principal with Holbrook & Manter, CPAs. Brian has been with Holbrook & Manter since 1995, primarily focusing on the areas of Tax Consulting and Management Advisory Services within several firm service areas, focusing on agri-business and closely held businesses and their owners. Holbrook & Manter is a professional services firm founded in 1919 and we are unique in that we offer the resources of a large firm without compromising the focused and responsive personal attention that each client deserves. You can reach Brian through

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